A/HRC/20/22 very narrowly defined circumstances. 50 This also serves the purpose of ensuring that journalists are not targeted for elimination as potential witnesses.51 60. The Inter-American Court of Human Rights is currently considering a case concerning death threats as a potential violation of the right to life. 52 The Inter-American Commission on Human Rights has adopted resolutions on the issue53 and has established a Special Rapporteur for Freedom of Expression; for more than a decade, the protection of journalists has been highlighted in the annual reports under the mandate.54 61. The African Commission on Human and Peoples‘ Rights has condemned the practice in resolutions setting out the obligations of States also to ensure accountability. 55 In 2004, the Commission appointed the first Special Rapporteur on Freedom of Expression and Access to Information in Africa, and the mandate holders have done important work in respect of the safety of journalists on the continent. 62. All three regional human rights courts have the authority to issue interim or provisional or preventative measures—legally binding orders to refrain from infringing rights, or to protect them. The Inter-American Commission on Human Rights as a quasijudicial body also has the power to order precautionary measures. It has done so with the specific aim of protecting the lives of journalists in respect of two matters during 2011,56 and four matters during 2010,57 albeit with mixed success. In each of these instances the Commission specifically directed the relevant States to take measures to ensure the lives of the journalists named. The African Commission on Human and Peoples‘ Rights has similar powers, but has not been asked to use it to protect journalists. These interim measures are potential access points that should be used more often by journalists who are under threat. While the Inter-American system is the leader on this front, the fact that the system of precautionary measures has been the subject of controversy should be pointed out. 63. Other regional IGOs have also taken initiatives in respect of the protection of journalists. The Organization for Security and Cooperation in Europe, for example, has made the safety of journalists one of its priorities. 58 50 51 52 53 54 55 56 57 58 See Council of Europe, Committee on Culture, Science and Education, ―The protection of journalists‘ sources‖ (2010); resolution 1729 (2010), para. 6.1.3.3; resolution 1438 (2005), para. 8 (v); and resolution 1636 (2008), para. 8.8. The Appeals Chamber of the International Criminal Tribunal for the Former Yugoslavia has also held that ―war correspondents must be perceived as independent observers rather than as potential witnesses for the Prosecution. Otherwise, they may face more frequent and grievous threats to their safety and to the safety of their sources‖. Prosecutor v. Radoslav Brdjanin and Momir Talic, case No. IT-99-36-AR73.9, Decision on Interlocutory Appeal of 11 December 2002, para. 42. Vélez Restrepo and family v. Colombia, case No. 12.658. See, for example, the Inter-American Declaration of Principles on Freedom of Expression (2000), approved by the Commission at its 108th session, para. 9. See www.cidh.oas.org/relatoria/index.asp?lID=1. See for example the Declaration of Principles on Freedom of Expression in Africa (2002), adopted by the Commission at its 32nd session, sect. XI, and the Commission‘s resolution ACHPR/Res.178(XLIX) of 2011 on the deteriorating situation of freedom of expression and access to information in Africa. PM 422/11 – Lucía Carolina Escobar Mejía, Cledy Lorena Caal Cumes, and Gustavo Girón, Guatemala; PM 115/11 – Journalists at La Voz de Zacate Grande, Honduras. PM 36-10 – Rodrigo Callejas Bedoya and family, Colombia; PM 196-09 (Extension) – Inmer Genaro Chávez and Lucy Mendoza, Honduras; PM 196-09 (Extension) – Journalists from Radio Progreso, Honduras; and PM 254-10 – Leiderman Ortiz Berrio, Colombia. See for example the OSCE Safety of Journalists Guidebook (2012), available from www.osce.org/fom/85777. 13